On November 26, 2014, the FFIEC release the revised Bank Secrecy Act/Anti-Money Laundering Examination Manual. The manual includes revised risk-based procedures, current guidance on risk-based policies, safeguard operations for money laundering and terrorist financing, and much more. The FFIEC recommended that financial institutions “should familiarize themselves with these revisions and make the necessary updates to [...]

“Narratives humanize problems,” said CFPB Director Richard Cordray. It was with that mentality that the CFPB adopted the overhaul of its Consumer Complaint Database to give consumers the opportunity to vent their frustrations through a written narrative. But the decision has continually been met with industry backlash. The reputational risk presented to lenders in the new [...]

The industry gave a collective sigh of relief when the CFPB announced a much-needed postponement of the new integrated mortgage disclosures deadline to Oct. 3. But before any of us get too comfortable in this postponement, it’s important financial institutions keep up their preparation for these new integrated disclosures. And one of those preparations should [...]

This week we're throwing it back to our most popular blog post from last year. SARs are tricky things, but AffirmX Analyst Rachel Osborn has broken down the essential elements of a SAR into a step-by-step process in this timeless post.    Suspicious Activity Report (SAR) narratives can be one of the more problematic areas of [...]

One of the first places a regulator will start during any given examination is by looking at a financial institution’s policies, which is one good reason you should keep yours in tip-top shape. How exactly do you build that perfect policy? Sometimes the best way to figure out how to make the perfect policy is [...]

Though smaller financial institutions had little role in the recent financial crisis, they were struck with heavy regulation to match the large institutions. And because of these burdens, the market share for smaller financial institutions is shrinking at an alarming rate. A report released this last February by the Harvard Kennedy School on "The State [...]

A version of this post was originally published on CU Insight. "DDoS botnet makes slaves of your home and office router" "How 40,000 Routers Got Hijacked" "Home routers co-opted into self-sustaining DDoS botnet" "DDoS attacks affecting more countries than ever before" If you're unclear on the prevalence of DDoS issues, all it takes is a [...]

When regulators talk about the root causes of the problems in a financial institution's Bank Secrecy Act and Anti-Money Laundering programs, invariably the cause that comes out at the top of their list is a weak culture of compliance. FinCEN is well aware of the problem, and has issued several documents outlining their ideal compliant [...]

Chances are you haven't crammed for a final in quite some time. But why not give the FFIEC Cybersecurity Exam the old college try? It’s been almost two years since the Federal Financial Institutions Examination Council announced the addition of a cybersecurity risk assessment to regular IT examinations. The addition came with good reason, as cyber [...]

Lending to military members is an ever-increasing concern, and it's an area the CFPB has already cracked down on. But due to a high volume of complaints exposed in a recent report, the CFPB may be coming down even harder. High CFPB scrutiny for servicemembers is nothing new. During the mortgage crisis, the CFPB determined that more than 700 [...]